What You Need to Know About OSHA Reporting & Recordkeeping Updates

OSHA is changing its policies on injury and illness reporting and recordkeeping. Read on to learn how the new updates will affect your facility and when you’ll have to comply.

Beginning in 2017, employers with more than 250 employees and those with 20 to 249 employees in specified high-risk industries must submit injury and illness logs annually to the Occupational Safety and Health Administration (OSHA). The information that OSHA obtains from these documents helps them to evaluate the overall safety of workplaces, establish trends and target their outreach efforts to industry sectors with higher than average incident rates.

OSHA will provide a secure website for employers to submit their data. The website is scheduled to go live in February 2017. Because electronic reporting is a new requirement for most facilities, reporting requirements will be phased.

In 2017 and 2018, establishments have a full 6 months to gather and submit their injury and illness logs for the previous year to OSHA. Beginning in 2019, however, OSHA requires all of the past year’s data to be submitted by March 2.

Date

Affected Industries

Forms to Submit

July 1, 2017

Establishments with 250 or more employees and establishments with 20 – 249 employees in certain high-risk industries

Recordable Injuries

Any injury that is work-related [29 CFR 1904.5] and is a new case [29 CFR 1904.6] must be reported if it meets any of the following criteria:

Fatality

Days away from work

Restricted work or transfer to another job

Medical treatment beyond first aid

Loss of consciousness

Work-related diagnosed case of cancer or a chronic irreversible disease

Fractured or cracked bones or teeth

Punctured eardrums

Needlestick exposures and sharps injuries

Occupational hearing loss

Occupational exposure to tuberculosis

Not every injury is recordable. Injuries and illnesses that only require first aid treatment do not need to be recorded in OSHA logs. The following actions are considered to be first aid treatment and do not need to be recorded in OSHA logs [29 CFR 1904.7(b)(5)(ii)]:

Using a nonprescription medication at nonprescription strength

Administering tetanus immunizations

Cleaning, flushing or soaking wounds on the surface of the skin

Using wound coverings (such as bandages, Band-Aids® and gauze pads) or using butterfly bandages or Steri-Strips™

Using hot or cold therapy

Using any non-rigid means of support, such as elastic bandages, wraps and non-rigid back belts

Drilling of a fingernail or toenail to relieve pressure or draining fluid from a blister

Using eye patches

Removing foreign bodies from the eye using only irrigation or a cotton swab

Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means

Using finger guards

Using massages

Drinking fluids for the relief of heat stress

It is important for employers to keep accurate records and to submit their reports annually if they are required to do so.

Some injuries, however, must be reported to OSHA in a timelier manner. If there is a fatality, OSHA must be informed within eight hours. If an employee is hospitalized, suffers an amputation or the loss of an eye, a report must be filled within 24 hours. OSHA maintains a 24-hour hotline at 1-800-321-6742 to allow employers to provide timely reporting of these types of incidents.

To facilitate recordkeeping and help ensure that information is consistently tracked, OSHA has three different types of forms to record workplace injuries and illnesses.

OSHA Form 300A: The Summary of Work-Related Injuries and Illnesses

From February 1 to April 30 of each year, a summary of all recordable injuries and illnesses (the OSHA Form 300A) must be posted in the workplace. It must be posted in places where other notices are typically posted and it cannot be altered, defaced or covered by other announcements or materials [29 CFR 1904.32(b)(5)]. You must also have a means of verifying that the information was posted in the workplace, such as a notice in employee bulletins or a dated photograph.

All facilities subject to electronic recordkeeping rules must submit this form annually beginning in January 2017.

OSHA Form 300: The Log of Work-Related Injuries and Illnesses

The OSHA 300 log is used to keep track of all recordable workplace injuries and illnesses throughout the year. It needs to be kept current and must be made available to OSHA compliance officers within four hours of a request. OSHA 300 logs must be electronically submitted to OSHA annually beginning in 2018 if the facility has 250 or more employees, 20 to 249 employees in designated industry sectors or if OSHA specifically requests it. Facilities must also keep this record onsite for five years.

The log includes information about who was injured, the type of injury or illness and what happened as a result of it: death, days away from work or duty restrictions, for example. OSHA clarifies how days away from work are to be recorded in 29 CFR 1904.7(b)(3).

OSHA Form 301: The Injury and Illness Incident Report

For each injury or illness reported on the 300 Log, a Form 301 must be completed [29 CFR 1904.29(b)(2)]. This form must be completed within seven days following an incident and must be kept for five years.

The 301 form provides details about the injury or illness that has occurred. This helps the employer recall facts about an event if they are needed at a later time and provides OSHA with specific information about how an injury or illness happened. Like the Form 300, beginning in 2018 workplaces with 250 or more employees will need to submit this log to OSHA annually.

Employee Rights

If workplace injuries or illnesses do occur, OSHA gives employees the right to report work-related injuries and illnesses and to do so without fear of retaliation. Employers must have a reasonable process for reporting injuries and illnesses and that process must be communicated with employees.

No employee should expect to be injured. That’s why OSHA takes recordkeeping seriously and requires employers to identify workplace hazards and put processes, procedures and safeguards in place to prevent injuries and illnesses. OSHA also requires employers to train their employees about hazards they may face and how to prevent them.

Requiring employers to submit their injury and illness records provides OSHA with valuable information that can be used to focus their efforts on rulemaking, guidance documents and outreach programs that help prevent future workplace incidents.

You can find more info about the new recordkeeping & reporting rule on this FQA page.

Wondering what OSHA will be looking for when an inspector shows up at your facility? Check out the OSHA Top 10 Violations list, updated every year in October, to see where most facilities fall short and get fines.

Do you have questions about OSHA’s updates to the recordkeeping & reporting rule? Leave us a comment below or submit your question here and we’ll get you an answer!

Karen

Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenea@newpig.com.

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